Spain has issued Royal Decree 252/2025 of 1 April 2025 in the Official Gazette, introducing Complementary Tax Regulations to ensure a global minimum tax for large multinationals and national groups.
The regulations clarify Law No. 7/2024 of 20 December 2024 for implementing the Pillar Two global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022.
This includes the introduction of the Pillar Two income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years.
The rules apply to all domestic and international groups with a parent company or subsidiary in an EU member state.
The bill also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups and certain safe harbors.
The IIR and QDMTT apply for financial periods beginning on or after 31 December 2023, while the UTPR generally applies for financial periods beginning on or after 31 December 2024.
The regulations cover rules for calculating the tax base and adjusted taxes, procedures for information returns and self-assessment, transitional provisions, and penalties.
Royal Decree 252/2025 came into effect yesterday, 3 April 2025.
